After Roe was decided, pro-life states passed laws trying to overturn the decision. Those efforts failed, but they resulted in Planned Parenthood v. Casey, which enabled the gradual chipping away of reproductive rights. Casey may have upheld the “essential holding” of Roe, but it dramatically altered the constitutional test for abortion laws. Replacing Roe’s difficult strict scrutiny test with a looser and vaguer test that merely requires abortion laws not to impose an “undue burden,” Casey emboldened states to enact abortion restrictions that “protect” women. Many states passed laws to prevent “hasty” or “uninformed” abortion decisions by requiring women to wait 24, 48 or sometimes 72 hours; by mandating ultrasounds before abortions; and by requiring disclosure of inaccurate or imbalanced information to dissuade women from abortion. Other laws impose targeted restrictions on abortion providers or clinics allegedly to protect maternal health. In fact, they offer no benefits and only burden women seeking abortions. While not blatantly violating Roe, these laws have dramatically reduced the number of abortion providers in many states. Together with waiting periods and ultrasound requirements, they make it extremely difficult, if not impossible, for women, especially poor and rural women, to access abortions in many states.